Julio Garcia Longoria v. State, 08-13-00083-CR

In 2008 an undercover detective (posing as a 15‑year‑old female “AlexG”) logged chat messages with appellant Julio Longoria in an El Paso internet chat room; the chat log was recorded and admitted at trial.
The chat included sexual solicitations (discussion of sex, condoms, oral sex) and an arranged meeting at a Diamond Shamrock; Longoria described his car and clothing in the chat.
Detective Rodriguez observed a gold car matching the description at the meeting place, identified Longoria as the driver, arrested him, Mirandized him, and obtained a written statement in which Longoria admitted chatting with a 15‑year‑old but denied intent to act.
Longoria was indicted for online solicitation of a minor (Tex. Penal Code § 33.021) alleging solicitation with intent that the minor engage in sexual intercourse, deviate sexual intercourse, and sexual contact; a jury convicted and the court assessed 3 years’ imprisonment.
Defense sought a continuance to obtain testimony from Dr. David Briones regarding Longoria’s mental impairment; the trial court denied the continuance, Briones did not appear, and the defense rested without obtaining his testimony or requesting attachment.
Longoria appealed, challenging (1) sufficiency of the evidence, (2) denial of compulsory‑process/continuance, and (3) admission/authentication of the chat log.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence to prove online solicitation of a minor	State: chat log, appellant's admission, and the meeting attempt proved each element beyond a reasonable doubt	Longoria: evidence is conjectural, no proof of actual intent to meet or commit sex	Affirmed — under Jackson/Brooks standard, evidence and reasonable inferences suffice for a rational juror to find guilt
Denial of continuance/compulsory process (Dr. Briones)	State: issue waived; defendant failed to preserve compulsory‑process complaint at trial	Longoria: denial prevented presentation of expert on mental impairment bearing on mens rea/intent	Affirmed — issue was forfeited for failure to timely object/preserve; no writ of attachment sought and witness failed to appear
Authentication/admissibility of chat log (State’s Exhibit 1)	State: detective party to chat and appellant admitted the log accurately represented the conversation, satisfying Rule 901	Longoria: chat log not properly authenticated	Affirmed — trial court properly made preliminary Rule 901/104(a) finding that evidence was sufficiently linked for the jury to assess authenticity

Jackson v. Virginia, 443 U.S. 307 (standard for sufficiency review)
Brooks v. State, 323 S.W.3d 893 (applying Jackson standard in Texas)
Tienda v. State, 358 S.W.3d 633 (Rule 104(a) gatekeeping and electronic authentication)
Hooper v. State, 214 S.W.3d 9 (circumstantial evidence sufficiency principles)
Guevara v. State, 152 S.W.3d 45 (circumstantial evidence probative value)
Washington v. Texas, 388 U.S. 14 (constitutional right to compulsory process)
Trenor v. State, 333 S.W.3d 799 (preservation/waiver of compulsory process complaint)